Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Revision proceedings under section 263 were held impermissible because the Assessing Officer conducted due enquiries and took a plausible view in restricting a deduction claimed under section 80P(2)(d) to profits from credit facilities to members. The AO verified accounts, investments and supporting details and disallowed the portion of the claim after application of mind; the superior officer's disagreement alone did not satisfy the twin conditions required to invoke revision u/s 263. Result: revision power not exercisable and the AO's assessment view is sustained in favour of the assessee.
Revision proceedings under section 263 were held impermissible because the Assessing Officer conducted due enquiries and took a plausible view in restricting a deduction claimed under section 80P(2)(d) to profits from credit facilities to members. The AO verified accounts, investments and supporting details and disallowed the portion of the claim after application of mind; the superior officer's disagreement alone did not satisfy the twin conditions required to invoke revision u/s 263. Result: revision power not exercisable and the AO's assessment view is sustained in favour of the assessee.
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